SITE INFORMATION AND CORRESPONDENCE 1980-1999

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STAFF REPORT CITY OF LODI WHITE SLOUGH WATER POLLUTION CONTROL PLANT SAN JOAQUIN COUNTY Two items are being considered for adoption: issuance of a renewed NPDES Permit for the White Slough Water Pollution Control Plant, and issuance of a Cease and Desist Order requiring the Discharger to cease and desist from discharging wastes in contrast to waste discharge requirement presented in the renewed NPDES permit. The White Slough Water Pollution Control Plant (Plant) is owned and operated by the City of Lodi. The Plant is located roughly 5 miles west of the City of Lodi and approximately 1 mile south of Interstate 5 and State Highway 12 freeway interchange. The Plant, with a designed dry weather flow of 8.5 mgd, treats primarily domestic wastes and to some extent a small commercial/industrial component. A majority of the industrial wastewater (primarily from food processors) is collected in a separate sewer and is either directly applied to reclamation fields or is stored in (40 acres) ponds prior being applied to the reclamation area. The Plant provides secondary level wastewater treatment consisting of screening, aerated grit removal, primary sedimentation, air activated sludge, secondary clarification, chlorine disinfection with dechlorination and surface water discharge. During summer months, unchlorinated treated domestic wastewater is not discharged to surface waters but is also applied to the reclamation area. Unchlorinated treated domestic wastewater is also reclaimed throughout the year as cooling water in a closed loop system at a cogeneration facility, and for mosquito fish rearing in ponds adjacent to the treatment plant. The location of the surface water discharge is roughly 3000 feet west of the Plant. When treated wastewater is discharged to surface water, it is to a dead-end portion of Dredger Cut, a water of the United States. Because there is limited to no dilution at the point of discharge and within Dredger Cut, no mixing zone has been proposed for this permit in order to protect aquatic life. On 5 November 1999, the tentative waste discharge requirements (WDR) and a Tentative Cease and Desist Order(CDO) for the Plant were circulated to the discharger and "All Concerned Persons and Agencies". On 3 December 1999, the two items were circulated for public review and comment. Comments from"Concerned Persons and Agencies" were due to Board Staff by 17 December 1999, while comments from the public were due to staff by 4 January 1999. A minimal number of comments were received from governmental agencies while no comments were received from the general public. However, numerous comments were received from the Discharger, the Discharger's consultant, and a third party environmental interest group. Based on the comments received, several changes were made to the tentative WDR; however, no changes were made to the CDO. Specific changes were made on the effluent limitations for residual chlorine and total suspended solids, and the turbidity and total coliform limitations that are to be effective 1 May 2004). Wording within Section D of the Order was changed to bring consistency with the definition of"reclaimed water". Wording was added to Finding 36 and Attachment C (Fact Sheet) to present cost estimates made by the Discharger with respect to the additional disinfection requirement. Wording in Sections G.1 and GA (Groundwater Limitation) and Section H.1 and H.2 (Provisions) was also changed with respect to pertinent comments. Changes to the Monitoring and Reporting Program include: the addition of turbidity monitoring for